Customs Proposes To Substantially Transform The Substantial Transformation Test
Client Alert | less than 1 min read | 08.08.08
By Notice of Proposed Rulemaking, 73 Fed. Reg. 43385 (July 25, 2008), Customs & Border Enforcement has proposed substituting, for many purposes including rulings under the Trade Agreements Act (TAA), a "tariff shift" approach for determining country of origin in lieu of the longstanding and subjective "case-by-case" approach to determining the place where "substantial transformation" occurred. Under the proposed rule, contractors selling products under the contracts subject to the TAA would have to reevaluate their products under the rigid, pre-established formulaic tariff shift analysis to ensure products with significant non-designated country content qualify for sale to the federal government.
Insights
Client Alert | 3 min read | 08.18.25
FCPA Enforcement Continues to Evolve with Newly Unsealed Indictment
On August 11, 2025, the U.S. Department of Justice (“DOJ”) announced that it had unsealed an indictment against two Mexican businessmen for alleged violations of the Foreign Corrupt Practices Act (“FCPA”). DOJ asserts that the defendants, both Mexican nationals living in Texas, paid bribes to officials at Petróleos Mexicanos (“PEMEX”), and its subsidiary, PEMEX Exploración y Producción (“PEP”) to secure contracts worth an estimated $2.5 million. These charges come amidst a period of uncertainty regarding FCPA enforcement following the Trump administration’s temporary pause on FCPA enforcement and the subsequent issuance of new investigation and enforcement guidelines.
Client Alert | 3 min read | 08.18.25
Recent GAO Sustain Includes Valuable Lessons on Proposal Preparation and More
Client Alert | 6 min read | 08.14.25
Changes in Sunscreen Regulation & Litigation are Heating Up: Updates from Congress to the Courts
Client Alert | 3 min read | 08.14.25
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